ML20214J093

Rev 2 to TVA Employee Concerns Special Program Rept 307.02-SQN, Handling Safeguards Info

ML20214J093
Person / Time
Site:	Sequoyah
Issue date:	11/13/1986
From:	Murphy M, Russell J TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20214H850	List: ML20214H848 ML20214H865 ML20214H879 ML20214H927 ML20214H956 ML20214H976 ML20214J008 ML20214J040 ML20214J053 ML20214J064 ML20214J083 ML20214J093 ML20214J101 ML20214J126 ML20214J135 ML20214J144 ML20214J161 ML20214J169 ML20214J180 ML20214J199 ML20214J206 ML20214J212 ML20214J220 ML20214J224 ML20214J231 ML20214J243 ML20214J251 ML20214J261
References
307.02-SQN, 307.02-SQN-R02, 307.02-SQN-R2, NUDOCS 8612010155
Download: ML20214J093 (8)

Text

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TVA EMPLOYEE CONCERNS REPORT NUMBER: 307.02-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 2 TITLE: Handlin6 Safeguards Information REASON FOR REVISION:

Incorporata SRP, TAS conunents and SQN Corrective Action Response Revision 1 Incorporate SRP conunents Revision 2 PREP &MATION PREPARED BY:

R. E. Jones //-@fd SIGNATURE DATE l

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                         / [       SIGNATURE                                                 DATE l       TAS*

ffN ll ? / SIGNATURE DATE l CONCURRENCES CEG-H: b . . e ~,.sv--- FS SRP: e ll 86 SIGNATURE DATE SIGNATURE

• DATE APPROVED BY:

Y N/Yl) l*l3-[h N/A ECSP MANA%ER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

       *SRP Secretary's slEnature denotes SRP concurrences are in files.

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TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Nuclear Power Site Programs and Procedures Element: Handling of Safeguards Information Report Number: 307.02-SQN Revision 2 11-85-018-001 IN-85-915-003 Evaluator: R. E. Jones 10/13/86 R. E. Jones Date Reviewed by: (( ops C

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                                                    !)psber            'Date Approved by:                   '    -       s V           /l-4-7b W. R. Lagel sq;en               Date l

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Revision 2 I. IMPROPER STORAGE AND CONTROL OF SAFEGUARDS INFORMATION The concerns expressed in this report are (1) Sequoyah Nuclear Plant (SQN) specific item dealing with safeguards material being improperly stored and controlled and (2) an employee concern considered generic to SQN that addressed lots of safeguards information. II. SPECIFIC EVALUATION METHODOLOGY This evaluation addresses two concerns. The employee concerns identified to Quality Technology Company (QTC) are i as follows: A. II-85-018-001 " Safeguards information at the Sequoyah Nuclear l Power Plant is being kept in uncontrolled books and l not secured as per TVA policy and/or NRC guidelines." B. IN-85-915-003 "A safeguards drawing (45 W 39-4 Revision 10) was lost. An investigation into this lost document stated it was destroyed. There is no objective evidence to support this report." Concern II-85-018-001 was closed by Nuclear Safety Review Staff (NSRS) investigation report I-85-135-WBN and evaluation of the concern for SQN is based on a review of the NSRS report and line management response to j the NSRS investigation. Evaluation of.this concern centered on the l validity of the employee concern, the adequacy of NSRS recommendations l to clo'se out the concern, a verification of the line management response to NSRS recommendations, and a review and verification of the corrective actions that resulted from the investigation. Concern IN-85-915-003 was considered as generic to SQN based on the results of an NSRS investigation I-85-459-WBN at Watts Bar and was evaluated at SQN as an open concern. The ECTG evaluation at SQN was based on the associated NSRS report recommendations and the line management responses to the report. Appropriate procedures at SQN were reviewed to determine the adequacy of the site procedures and interviews were conducted to verify that the program is being properly implemented. III. FINDINGS Improperly Stored Safeguards Material (Concern 11-85-018-001) NSRS investigation report number I-85-135-WBN substantiated the concern of improperly stored and controlled safeguards material at SQN. The investigating team (composed of NSRS, Public Safety Service (PSS), and Quality Technology Company (QTC) personnel) found safeguards documents in a locked PSS office which were not protected or accounted for in a manner that met Nuclear Regulatory Control (NRC) regulations and TVA policy / procedures. , Page 1 of 5

Revision 2 As a result of the investigation the following NSRS recommended actions were taken by line managemant: (1) The safeguards material was immediately transported to a proper storage area before departure of the investigating team; and (2) the Sequoyah Public Safety Service issued Security Degradation / Incident Report Number 85-051-06 and accounted for all safeguards documents. The NSRS investigation determined that the improperly stored documents had not been compromised and SQN PSS subsequently reinstructed all members of the security force on their individual responsibilities involving the safe handling and storage of safeguards material. This action is documented in a memorandum dated September 5, 1985 (reference 2). Lost Safeguards Drawing (Concern IN-85-915-003) Title 10 CFR 73 and NUREG-0794 establishes the requirements for the

protection of safeguards information. Evaluation of SQN procedures 0401.01 (reference 5), AI-25, part I (reference 7), AI-25, part II (reference 8), and Standard Practice SQA-132 (reference 6) determined that the regulatory requirements are adequately incorporated into the SQN program. Further, evaluator interviews with SQN Security and Document Control personnel confirmed that these personnel have sufficient knowledge of these procedures to implement the program.

NSRS investigation report I-85-459-WBN, which was written to address the problem originally at WBN, included a recommendation to revise the Document Control Safeguards Document Log to include a reference to the drawing revision and unit applicability as additional information to i provide additianal controls for traceability beyond that of the drawing , l number. A review of the Safeguards Log at SQN determined that this NSRS recommendation is also applicable to SQN and at present has not been implemented. Conclusion NSRS Report I-85-135-WBN adequately addressed concern XX-85-018-001. Line management's response was adequate and corrected the deficiencies found during the investigation. l l l Page 2 of 5

Revision 2 Employee Concern XX-85-018-001 was substantiated at SQN. However, adequate corrective action was immediately implemented and resolved the specific concern. Employee Concern IN-85-915-003 was not substantiated at SQN. A review of SQN safeguards information procedures identified no programmatic deficiencies. However, this evaluation concurs with the NSRS recommendation made at Watts Bar that the Document Control Safeguards Document Log should be revised to include the drawing revision number and unit applicability number on the form. At present, the form used at SQN does not utilize these identifiers. The concerns addressed in this report have no safety significance at SQN. IV. ROOT CAUSE Personnel error in not following procedures. V. GENgEIC APPLICABILITY Employee Concern 11-85-018-001 is not generically applicable to other TVA plant sites. Based on the findings of this report, SQN safeguards procedures adequately address regulatory requirements for the protection of safeguards information. The incident addressed during this evaluation was not the result o.f programmatic deficiencies but was an isolated occurrence of personnel r.ot following procedures. Employee Concern IN-85-915-003 remains generically applicable to BFN because an adequate evaluation of the BFN Safeguards Information Program has not been conducted to determine adequacy. 1 Page 3 of 5

Revision 2 VI. REFERENCES

1. NSRS Investigation Report Number I-85-135-WBN, " Safeguards Information (SQN)"

2. Nemorandum from John S. Rozek to K. W. Whitt dated September 5, 1985, "NSRS Investigation Report Number I-35-135-WBN"

3. Code of Federal Regulations, 10 CFR 73

4. NUREG-0794, " Protection of Unclassified Safeguards Information"

5. SQN Procedure 0401.01, " Protection of Safeguards Information Within the Division of Nuclear Power"

6. SQN Standard Practice SQA-132, " Safeguards Information Program"

7. SQN Administrative Instruction AI-25 (Part I), " Drawing Control After Licensing"

8. SQN Administrative Instruction AI-25 (Part II), " Revision of As-Constructed Drawings"

9. NSRS Investigation Report I-85-459-WBN, " Safeguards Drawing Incident" VII. IlgtEDIATE OR LONG-TERN CORRECTIVE ACTION SQN's response to 307.02-SQN Revision 0 is as follows IR2 (CATD_30702-SQN-01): l A. I-85-459-WBN Safeguards Document Log Revision Required The Safeguards Document Log now utilized by the DCU should be changed to include revision and unit applicable notations.

Action "The Sequoyah Safeguard Document Log was immediately revised upon notification of recommendation to include revision and applicable unit (s)." B. I-85-459-WBN Guidance for Safeguards Incideat Investigetion l The involved line organizations should seek clarification and guidance in regard to implementation of safeguards incident investigations and disposition. That clarification and guidance received should be translated into working level instructions and training. Page 4 of 5

Revision 2 Action

                 " Office of Nuclear Power at Sequoyah Standard Practice SQA-132 Safeguards Information Program adequately addresses the handling of safeguards information. Training was conducted at Sequoyah on July 11, 1986 - September 12, 1986 for personnel handlingsafeguard information (see attached). Management at Sequoyah is to ensure their personnel are aware and adhere to safeguard requirements."

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PAGE REFERENCE - ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY RUN TIME 'II:4 OFFICE OF NUCLEAR P0HER RUN DATE - 10/2 FREQUENCY - REQUEST EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) . g ONP - 1555 - RHM LIST OF EMPLOYEE CONCERN INFORMATION - SUBCATEGORY: 30702 HANDLING OF SAFEGUARDS INFORMATION CATEGORY: OP PLANT OPER. SUPPORT KEYHORD A l S GENERIC KEYHORD B g H APPL QTC/NSRS P S CONCERN KEYHORD C CONCERN SUB R PLT BBSH INVESTIGATION R DESCRIPTION KEYHORD D NUMBER CAT CAT D LOC FLQB REPORT A SAFE-GUARDS DRAHING (45H39-4 REV 1 FALSIFICATION I IH 00000 S HBN NNYN I-85-459-HBN 0) HAS LOST. AN INVESTIGATION INTO DOCUMENT STATUS IN 915-003 30702 REPORT CONSTRUCTION T50133 OP THIS LOST DOCUMENT STATED IT HAS DES f GENERAL TROYED. THERE IS NO OBJECTIVE EVIDE y NCE TO SUPPORT THIS REPORT. (ADDITI ONAL FACTS / NAMES ARE KNDHN, HITHELD DUE TO CONFIDENTIALITY). CI HAS NO FURTHER INFORMATION. D SS SAFEGUARDS INFORMATI0H AT THE SEQUAY POWER XX 018-001 OP 30702 N SQN NNNN AH NUCLEAR P0HER PLANT IS BEING KEPT SECURITY K-FORM OPERATIONS T50022 IN UNCONTROLLED BOOKS AND NOT SECUR SECURITY g ED AS PER TVA POLICY AND/OR NRC GUID ELINES (LOCATIONS, INDIVIDUALS KNOHN

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2 CONCERNS FOR CATEGORY OP SUBCATEGORY 30702 9

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